Wednesday, 12 August 2015

Risk adjustment can't be claimed without quantifying risk and its effect on adjustment of ALP

IT/ILT : TPO erred in modifying selection criteria used by assessee, i.e., salary and wages cost ratio of 50 per cent, and applying 25 per cent criteria for same, when in preceding assessment year assessee had applied similar filter and applying +/- 15 per cent range as applied by TPO in preceding year, such range came to 48.91 per cent to 78.91 per cent which was close to salary and wages cost ratio of 50 per cent applied by assessee

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